Planned Maintenance, Startup, and Shutdown –
Other Industries
Mike Coldiron , P.E.Air Permits Division
Texas Commission on Environmental QualityAdvanced Air Permitting Seminar 2012
What Are Planned MSS Emissions?
• Planned MSS emissions include air emissions resulting from the maintenance, startup, or shutdown of equipment or facilities at a site
What Are Planned MSS Emissions?
• Part of normal or routine facility operations other than production operations
• Predictable to timing
• Do not have to be scheduled for a specific date or time
What Are Planned MSS Emissions?
• Do not include unplanned MSS, upsets, or emission events– TCEQ does not permit unplanned MSS,
upsets, or emission events– Emission events are covered under 30
TAC §101.201
MSS Permitting – Other Industries
• Diversity very different from previous industry groups
• Different industry demographics - small businesses and minor sources (sites)
MSS Permitting Goals – Other Industries
• Reduce the amount of effort for staff and regulated community
• Reduce processing times
• Efficiently review MSS from the large number of permitted sources anticipated for the 2013 submittal
MSS Permitting – Previously Permitted Industries
Number of Applications Received by DateRefineries 26 January 5, 2007
Chemical plants 400 January 5, 2008
Carbon black 6 January 5, 2010
Power plants 103 January 5, 2011
MSS Permitting – Coatings Industry
Foam Manufacturing 35
Printing 55
Fiber Reinforced Plastics/Cultured Marble 91
Paint, Coatings, Ink, and Adhesive Mfg. 43
Degreasing 18
Semiconductors and Electronics 32
Enclosed Painting 297
Non-enclosed Painting 43
Abrasive Blasting 23
Miscellaneous 56
MSS Permitting – Mech/Ag/Construction Industry
Cotton Gins 267Grain Elevators 693Concrete Batch Plants 1015Hot Mix Asphalt Plants 284Rock Crushers 488Feed Mills 81
Total number of Mechanical Section applications is expected to exceed 3000
MSS Permitting – Chemical Process Industry
Bulk and Marine Terminals 199Cleaning Facilities (i.e., railcar cleaning)
86
Refuse and Offsite Treatment 38Chemicals and Allied Services 37
MSS Permitting – Planned MSS Groupings
• Evaluated possible MSS activities for each industry type
• Created groupings of similar industry types with similar MSS activities
• Discussed options for authorizing those activities
Activity Categories for MSS
• Process MSS
• General facility MSS– Included in other industry submissions– Impacts issues are difficult to deal with
Approach for Process MSS Activities
• Identified specific facility types
• Identified for each facility type– What is MSS– What is not MSS (normal process)
• MSS activities may be common to different facilities
• Authorization options
Process MSS Authorization Options
• Already authorized in current permit explicitly or implicitly
• PBR – 30 TAC Chapter 106– No registration in most cases– Simple (or no) recordkeeping– No BACT review or public notice– Limited (or no) impacts review
Process MSS Authorization Options
• De minimis – 30 TAC §116.119– No registration– Simple (or no) recordkeeping– No BACT review or public notice– Limited impacts review
Examples of Process MSS Using PBR §106.263
• Temporary control devices for degassing
• Thermal control device startup and shutdown
• Process piping replacement or repair
Approach for General Facility MSS
• Identify common activities• Approach to authorization
– De minimis under 30 TAC §116.119– PBR
General Facility MSS Authorization Options
• De minimis – 30 TAC §116.119– No registration– Simple (or no) recordkeeping– No BACT review or public notice– Limited impacts review
General Facility MSS Authorization Options
• PBR – 30 TAC Chapter 106– No registration in most cases– Simple (or no) recordkeeping– No BACT review or public notice– Limited (or no) impacts review
Examples of General Facility MSSDe Minimis - §116.119
• Glove box blasting cabinets
• Aerosol cans (< 64 ounces/day)
• Vehicle/equipment washing
Examples of General Facility MSSDe Minimis - §116.119
• Instrument calibration/leak checking
• Non-aerosol lubricants
• Aqueous detergents
Examples of General Facility MSS Using PBRs
• Facility painting/blasting: §106.263
• Parts cleaners: §106.454
• Welding: §106.227
• Hand-held equipment: §106.265
MSS Authorization Requirements - Amendments
• Identify planned MSS activities • Quantify emissions
• BACT required– May include restrictions on activities– May be work practices
MSS Authorization Requirements - Amendments
• Impacts analysis required – Use MERA– Air dispersion modeling may be required
• Public notice may be required – New air contaminants – Increased emissions > PN Triggers
Implementation Tools – Coatings Sources
• Form PI-MSS for surface coating sources
• Example application based on Form PI-MSS
• Updated MSS BACT Tables
• Frequently Asked Questions
Implementation Tools – Mech/Ag/Construction
Industry• Survey to gather information
• Outreach to industry
• Early MSS review
Implementation Tools – Chemical Sources
• Chemical Section Toolbox on Air Permits page of TCEQ Web site will include the following:– Guidance documents– Instructions– Calculation spreadsheets– BACT tables– FAQs
Summary• Applications for “other sources” are due
by 01/05/13
• Timely applications will preserve the affirmative defense
• BACT and an impacts analysis will be required for permit amendments
Summary• Use PBR or de minimis for general
facility MSS activities
• Use the implementation tools developed by APD
• Work with APD during application development
Phone Numbers
APIRT: (512) 239-3075 APD: (512) 239-1240 or
1250
Contact Information
Contact information for the Coatings MSS Team is located on the announcements page of the TCEQ Web site.